Campbell v. Acuff-Rose Music, Inc. is a landmark Supreme Court case from 1994 that determined the boundaries of fair use in copyright law, specifically in relation to parody and transformative works. The case arose when the hip-hop group 2 Live Crew created a parody version of Roy Orbison's song 'Oh, Pretty Woman,' which led to a significant legal discussion about whether the parody constituted fair use under copyright law. The ruling clarified that transformative works can qualify for fair use even if they are commercial in nature, emphasizing the importance of creative expression in the realm of copyright.
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The Supreme Court ruled in favor of 2 Live Crew, stating that their parody transformed the original song into something new and different.
The decision underscored the significance of artistic expression and creativity, allowing for more freedom in parody and satire.
The case established that commercial intent does not automatically negate fair use; even commercial parodies can be considered transformative.
The ruling emphasized a balancing test to determine fair use, which considers factors such as purpose, nature of the original work, amount used, and effect on the market.
Campbell v. Acuff-Rose Music, Inc. has since become a foundational case in discussions about copyright law and fair use, often cited in subsequent legal disputes.
Review Questions
How did the ruling in Campbell v. Acuff-Rose Music, Inc. redefine the understanding of fair use in copyright law?
The ruling clarified that fair use could apply to transformative works, even those created for commercial purposes. It established that a parody could qualify as fair use if it significantly alters the original work by adding new expression or meaning. This decision shifted the focus from strict adherence to copyright protections towards a more flexible approach that values artistic creativity and expression.
What were the key factors considered by the Supreme Court in determining whether 2 Live Crew's song constituted fair use?
The Supreme Court evaluated several factors to determine fair use: the purpose and character of the use (commercial vs. nonprofit), the nature of the original work (creative or factual), the amount used in relation to the original (how much of the song was sampled), and the effect on the market for the original work (whether it undermined sales). The Court found that 2 Live Crew's parody was transformative and did not harm the market for Orbison's original song.
Evaluate the implications of Campbell v. Acuff-Rose Music, Inc. for future cases involving copyright and parody. How might this case influence creators and artists today?
The implications of this case are far-reaching, as it established a precedent for how courts evaluate claims of fair use concerning parody and transformative works. Future cases involving copyright will likely reference this ruling to justify creative expression while still adhering to copyright law. For creators and artists today, this decision empowers them to explore satire and parody without excessive fear of litigation, encouraging innovation and cultural commentary through their works while navigating copyright constraints.
Related terms
Fair Use: A legal doctrine that allows limited use of copyrighted material without permission from the rights holders under certain circumstances, including criticism, comment, news reporting, teaching, scholarship, or research.
Transformative Work: A work that adds new expression or meaning to an existing work and does not merely replicate it, which can qualify for fair use protection.
Copyright: A legal right granted to creators of original works of authorship, giving them exclusive rights to use, distribute, and display their work for a specified period of time.
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